Extended Producer Responsibility in Germany: Laws

Extended Producer Responsibility (EPR) in Germany holds manufacturers accountable for their products’ entire lifecycle, encompassing production, take-back, and disposal of products and packaging. It aims to enhance sustainability by conserving resources and promoting reuse.

Manufacturers in Germany are required to meet specific obligations under EPR. Presently, nearly all companies in Germany are impacted, particularly manufacturers and initial distributors of electrical and electronic equipment, batteries and accumulators, and certain registered packaging.

All producers and initial distributors of goods affected by the ElektroG (Electronics Law), Battery Law (BattG), or Packaging Law (VerpackG) in Germany are also subject to EPR (Extended Producer Responsibility). Consequently, they must comply with individual requirements derived from the respective laws. As part of Extended Producer Responsibility in Germany, registration with the competent authority is mandatory for every producer and initial distributor in Germany.

What does Extended Producer Responsibility entail in Germany?

Extended Producer Responsibility (EPR) imposes on producers and retailers the responsibility to not only focus on production but also to take back and dispose of their manufactured goods and packaging. The aim of this obligation is to ensure a more sustainable circular economy.

To reduce the amount of waste, Extended Producer Responsibility creates requirements for reusing or repairing products. The increasing amount of waste needs to be addressed considering several global issues.

For manufacturers and initial distributors of goods, there are various obligations that vary depending on the product group:

If you’re impacted by Extended Producer Responsibility and need guidance, Deutsche Recycling Service GmbH is your dependable partner for environmental compliance. With our comprehensive service program, we efficiently manage all EPR requirements in Germany and worldwide on your behalf.

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We’ll assess your company’s compliance with legal requirements, identify areas for process improvement, and explore opportunities for cost optimization.

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Which Products Are Covered by Extended Producer Responsibility in Germany?

In Germany, Extended Producer Responsibility applies to, among other things, the following products or packaging:

• Electrical and electronic equipment (ElektroG)
• Batteries and accumulators (BattG)
• Packaging of packaged goods (VerpackG)

Thus, a large number of companies are affected by Extended Producer Responsibility. Mandatory requirements have been implemented and partly anchored in legal regulations. These are expressed, among other things, in the ElektroG, BattG, and VerpackG. However, end-of-life vehicles, waste oil, and used tires are also subject to Extended Producer Responsibility. For you as a manufacturer and initial distributor, this now primarily means one thing – to face possible future legislative changes steadfastly with the right preparations.

Deutsche Recycling GmbH – Your Reliable Partner in Environmental Compliance

If you are affected by Extended Producer Responsibility and seek advice, we, Deutsche Recycling Service GmbH, are your reliable partner in environmental compliance matters. Thanks to our comprehensive service program, we are capable of coordinating and handling all requirements concerning Extended Producer Responsibility in Germany and worldwide for you.

Detailed Specifications Using the Example of the Electrical Law

The Electrical Law (ElektroG) covers electrical and electronic equipment, reflecting Extended Producer Responsibility in Germany. Manufacturers are required to take back their devices and inform users of this obligation. Different take-back requirements apply depending on business size.

Stores in Germany selling electrical and electronic equipment, with at least 400 m² of sales space, must, for example, offer containers for the disposal of electrical and electronic equipment in accordance with the EPR. Smaller stores have differing requirements.

For more ElektroG details, refer to our blog post on the legal obligation to take back electrical equipment. Also, see our post on ElektroG in 2023 – what’s changing?

Regulations Also Cover Online Platforms

From July 1, 2023, online platforms must verify product and packaging registration. This aims to foster a sustainable circular economy by reusing resources or proper disposal. This expansion of the Electrical Law demonstrates new obligations across product categories. Staying updated and seeking competent support is crucial for compliance. Deutsche Recycling GmbH offers full-service environmental compliance support.

Does Extended Producer Responsibility in Germany also apply to international trade?

Traders selling their goods internationally must adhere to international law when exporting. Similarly, companies or importers from other countries selling or exporting their goods and packaging to Germany are obligated to comply with German laws.

To continue from the perspective of traders based in Germany who sell abroad: On one hand, foreign laws may differ from German laws, such as the ElektroG (Electronics Law), Battery Law (BattG), and/or Packaging Law (VerpackG). On the other hand, in some countries, there is Extended Producer Responsibility for products where there is no such responsibility in Germany.

Are you affected by cross-border EPR or will you be in the future? In either case, we are here to support you with our services and coordinate global requirements as part of our comprehensive offerings.

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Where can manufacturers find support in complying with legal requirements and Extended Producer Responsibility in Germany?

Deutsche Recycling Service GmbH provides manufacturers and traders with a full range of services. This includes conducting a compliance check, if desired, to assess your company’s compliance with the requirements of Extended Producer Responsibility in Germany. Alternatively, we can start directly with our work to ensure compliance with regulations. These services include:

What sanctions are imposed if Extended Producer Responsibility is disregarded in Germany?

Goods that are not registered in accordance with Germany’s Extended Producer Responsibility are subject to administrative and civil penalties. Whether the lack of registration is intentional or unintentional does not matter. Penalties of up to €100,000 and a sales ban can be imposed. Furthermore, your competitors can make claims for damages due to your advantage.